OPINION
REBECA HUDDLE, Justice.
Appellants, J. Frederick Welling and 57 Off Memorial Apartments, LP (Welling), filed an appeal in district court, pursuant to Chapter 42 of the Texas Property Tax Code, challenging the Houston County Appraisal District's appraised value of two commercial properties for the 2010 tax year. HCAD moved to dismiss for lack of subject-matter jurisdiction alleging that Welling had failed to substantially comply with section 42.08...
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